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Strengthening Fiduciary Hygiene: Navigating DOL Scrutiny and New Litigation Risks for Health and Welfare Plans

For decades, fiduciary litigation under the Employee Retirement Income Security Act of 1974 (ERISA) was largely concentrated on 401(k) and pension plans. That era has ended. In recent years, we have seen class-action lawsuits...more

Consolidated Appropriations Act of 2026: The New Landscape of PBM Fiduciary Oversight

The Consolidated Appropriations Act of 2026 (CAA 2026), signed into law on February 3, 2026, includes provisions that reform how group health plans contract with pharmacy benefit managers (PBMs). The legislation is designed...more

White House Unveils Proposed ‘Great Healthcare Plan’: Considerations for Employer Health and Welfare Plan Sponsors

The US administration announced the “Great Healthcare Plan” on January 15, 2026, outlining a framework for potential healthcare reform focused on cost containment, consumer choice, and transparency. The proposal builds on...more

DOL Updates FY 2026 Health Plan Enforcement Priorities: What Employers Need to Know

The US Department of Labor’s Employee Benefits Security Administration (EBSA) has announced updated enforcement priorities for fiscal year 2026. These changes signal where EBSA will focus its investigative and enforcement...more

Straight to the Source: What Direct Drug Models Mean for Employer Plan Sponsors in 2026

Alternative prescription drug access models—including direct-to-employer (DTE) and direct-to-consumer (DTC)—are gaining traction as employers reassess traditional pharmacy benefit manager (PBM)-based pricing structures. As...more

GLP-1 Coverage, Obesity, and the ADA: What Employer Health Plan Sponsors Need to Know

Glucagon-like peptide-1 receptor agonists (GLP-1s) such as Ozempic, Wegovy, Mounjaro, and Zepbound have reshaped the landscape of diabetes and obesity treatment and quickly become one of the most significant cost drivers for...more

Clearing the Smoke: Insights from the Williams v. Bally’s Tobacco Use Surcharge Dismissal

In Williams v. Bally Management Group, LLC, the US District Court for the District of Rhode Island became the first court to grant a motion to dismiss in a class action challenging Bally Management Group’s (Bally) tobacco...more

Preparing for a Successful Annual Benefits Enrollment

Annual benefits enrollment, which for many companies will be in the coming months, typically lasts one to two weeks, but the preparation process begins several months in advance. For human resources (HR) and benefits teams,...more

One Big Beautiful Bill: Impact on Welfare Benefits

President Donald Trump signed the One Big Beautiful Bill (OBBB) into law on July 4, 2025. The OBBB is a wide-ranging piece of legislation that introduces significant reforms across multiple areas of federal policy, including...more

Reproductive Healthcare Privacy Final Rule Vacated by Texas Court

The US District Court for the Northern District of Texas on June 18, 2025 vacated portions of the HIPAA Privacy Rule to Support Reproductive Health Care Privacy (2024 Final Rule) related to reproductive healthcare privacy....more

On the Basis of Sex: HHS Rescinds Prior Section 1557 Guidance Interpreting Sex-Based Discrimination

The US Department of Health and Human Services (HHS) has rescinded several pieces of informal guidance, including its 2021 interpretation of Section 1557 of the Affordable Care Act (Section 1557), in response to executive...more

Executive Order Targets Prescription Drug Pricing: Potential Impact on Group Health Plans

President Donald Trump issued an executive order (EO) on May 12, 2025 to address the high cost of prescription drugs in the United States with the goal of ensuring Americans have access to most-favored-nation (MFN) pricing,...more

Mental Health Parity Non-Enforcement Statement Released

The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) announced their non-enforcement policy on May 15, 2025, indicating they will not enforce any new requirements imposed by the...more

US District Court Grants Freeze on Mental Health Parity Enforcement

The US Departments of Health and Human Services, Labor, and the Treasury (together, the Departments) filed a motion to suspend the litigation proceedings in The ERISA Industry Committee vs. HHS et al. on May 9, 2025 while the...more

US Administration’s Executive Orders and Actions’ Impact on Group Health Plans

Since taking office, President Donald Trump has issued several executive orders (EOs) and actions that may have an impact on group health plans. These EOs provide insight into the US administration’s policies and outline...more

Tobacco Surcharge Lawsuits: Considerations for Plan Sponsors

A growing number of class action lawsuits have been filed against employer-sponsored self-insured group health plans alleging that tobacco cessation wellness programs violate key provisions of the Employee Retirement Income...more

HHS Proposes Security Rule Update: What Group Health Plans Need to Know

The US Department of Health and Human Services (HHS) on January 6, 2025 issued a notice of proposed rulemaking (NPRM) seeking feedback on proposed updates to the Security Standards for the Protection of Electronic Protected...more

Welcome Healthcare Reporting Simplification Enacted

On December 23, 2024, President Biden signed into law two bills that will simplify employer reporting compliance under the Affordable Care Act (ACA). The new laws streamline the rules for employers furnishing ACA reporting...more

Fiduciary Considerations Raised By the Use of AI in Group Health Plans

The use of artificial intelligence (AI) in the administration of group health plans is nothing new: AI has been used for a number of years to analyze data, improve risk assessment, identify fraud, and streamline claims...more

Despite Challenges to Reproductive Healthcare Privacy Final Rule, Plan Sponsors Should Still Comply by December 23

The US Department of Health and Human Services’ (HHS) final rule on reproductive healthcare privacy is already subject to challenge even before its effective date. As described in our previous blog post, the HHS issued final...more

CMS Disclosures Due October 15: Is Your Plan’s Rx Coverage Still Creditable?

The Inflation Reduction Act (IRA) made several changes to Medicare Part D that may impact whether employer-sponsored coverage will be creditable for the 2025 plan year. With open enrollment season about to begin, plan...more

Federal Agencies Release Final MHPAEA Regulations: Navigating the Key Changes

The US Departments of Health and Human Services, Labor, and the Treasury (collectively, the Departments) released their much anticipated final rules implementing the Paul Wellstone and Pete Domenici Mental Health Parity and...more

DOL Reiterates Its Focus on Cybersecurity with Updated Guidance

The US Department of Labor (DOL) issued a press release on September 6, 2024 reminding ERISA plan fiduciaries that it considers cybersecurity to be an area of “great concern” and emphasizing that it continues to investigate...more

HHS Issues Final Regulations on Section 1557: Implications for Health Plans

The US Department of Health and Human Services (HHS) recently issued final regulations implementing Section 1557 of the Patient Protection and Affordable Care Act, which will restore and expand the scope of civil rights...more

OCR Releases Final HIPAA Privacy Rule to Support Reproductive Health Care Privacy

The US Department of Health and Human Services, Office for Civil Rights (OCR) published its Final Rule titled HIPAA Privacy Rule to Support Reproductive Health Care Privacy in the Federal Register on April 26, 2024....more

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